California Consumer Privacy Choices

Effective Date: February 1, 2023

Martin Resorts, (“Martin Resorts”, “we,” “us,” or “our”) are committed to the privacy concerns of California residents. California residents have specific rights under the California Consumer Privacy Act (CCPA) and other laws regarding their personal information. Our California Privacy Choices page provides California consumers with a one-stop shop to learn about our privacy practices, your legal rights and privacy choices, and other important information. To make it as easy as possible, we have provided important links to help you navigate this page.

California Consumer Privacy Act Disclosures

• Notice at Collection. Learn more about the categories of personal information we collect as a CCPA-covered business and the purposes for which it is used.
• California Privacy Policy. View our comprehensive disclosures regarding the collection, use, disclosure, and sale of your personal information and understand your rights under the CCPA.
• Submit a CCPA Request. Exercise your rights under the CCPA, including your right to know, correct, or delete the personal information we have collected about you.
• Do Not Sell or Share My Personal Information. Opt-out of the sale or sharing of your personal information to third parties.
• Notice of Financial Incentive. Learn more about how we incentivize you when we use your personal information.
• Workforce Member Privacy Policy. Applicable to California residents who are or are looking to become a workforce member of Martin Resorts or one of its group entity companies. 

California Privacy Policy

This California Privacy Policy supplements the information contained in the Privacy Policy and applies solely to visitors, users, and others who are residents of the State of California. This section describes your rights under the California Consumer Privacy Act of 2018 and all subsequent amendments (the “CCPA”), and other California laws. Any terms defined in the CCPA have the same meaning as when used herein. 

While we have set out the categories below as required by the CCPA, you can review our Privacy Policy for examples and other information that describes our data collection and use, which will not change under this notice.

Workforce Members and Candidates. Our processing of the personal information of job applicants/candidates and workforce members is not governed by this policy. That processing is described in our Workforce Member Privacy Policy. 

Notice at Collection: The Personal Information We Collect

This Section provides notice of our personal information collection and use practices with respect to California residents. For ease of reference, we have presented the relevant information in a chart explaining our collection, use, and disclosure practices related to California residents. You can learn more about our specific practices by reading our more detailed disclosures in our Privacy Policy, including learning more about the terms used in this chart. 

Categories of Personal Information	Categories of Sources from which the Information was Collected	Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose	Types of Third Parties with Whom this Category of Personal Information Is Shared/Sold
Identifiers (e.g., name, signature, address, telephone email, IP address)	You (or your device) Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Publicly Available Sources	Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Governmental Entities	Marketing and Advertising Providers
Personal Information in California Customer Records (such as name, contact information, government-issued ID, and financial information)	You (or your device) Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Publicly Available Sources	Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Governmental Entities	Marketing and Advertising Providers
Protected Classifications (e.g., Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status).	You (or your device) Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Publicly Available Sources	Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Publicly Available Sources Governmental Entities	We do not sell or share
Biometric Information	You	Business Service Providers Governmental Entities	We do not sell or share
Internet/Network Activity (your browsing history, search history).	You (or your device)	Business Services Providers Governmental Entities Affiliates	Marketing and Advertising Providers
Geolocation Data	You (or your device) Business Service Providers	Business Services Providers Governmental Entities Affiliates	Marketing and Advertising Providers
Sensory Data (e.g., Audio, electronic, visual, thermal, olfactory, or similar information).	We may collect your image, voice, electronic activity, or other sensory data through recording devices such as a security camera, call recording device, or thermal image scanner.	Business Services Providers	We do not sell or share
Professional or employment-related information (e.g., Current or past job history or performance evaluations).	We do not collect from consumers generally. See our Candidate Privacy Policy for additional disclosures for workforce candidates.	We do not sell or share	We do not sell or share
Education Information	We do not collect from consumers generally. See our Candidate Privacy Policy for additional disclosures for workforce candidates.	We do not sell or share	We do not sell or share
Inferences drawn from other personal information	We may make inferences about your preferences, likes, and interests based on personal information you provide to us.	Business Services Providers Marketing and Advertising Providers	Marketing and Advertising Providers
Sensitive Personal Information	Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Publicly Available Sources Governmental Entities	Hotel Operations Providers Property Owners Travel Providers Hospitality Service Providers Affiliates Business Services Providers Marketing Advertising Providers Governmental Entities	We do not sell or share

Our Purposes for Collecting and Using Your Personal Information

Our purposes for collecting and using your personal information include the following:

• Delivering Our Hospitality Services to you and to provide the related customer support, communication, and security. We provide all of the services common with the hotel and hospitality industry and our use of your personal information is consistent with providing our hospitality services.
• Customer Service to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
• Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
• Policy Enforcement, including enforcing our terms of stay and service, acceptable use policies, anti-spam policies, and similar policies.
• Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
• Contextual and Behavioral Targeting to provide contextual customization of ads shown as part of an interaction with our website or application, using tracking technologies like cookies and pixels.
• Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.
• Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.
• Public Health and Safety to ensure the health and safety of our guests, our workforce members, and the general public.
• Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.

Retention

We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your California Privacy Rights

California Residents have certain rights under the CCPA. For information on how to exercise these rights, please see below.

• The Right to Know. The right to know what personal information Martin Resorts has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about you.
• The Right to Deletion. The right to delete personal information that the business has collected about you, subject to certain exceptions.
• The Right to Correction. The right to correct inaccurate personal information that a business maintains about a consumer.
• The Right to Opt-Out of the Sale/Sharing. If we sell or share personal information, the right to opt-out of the sale or sharing of your personal information by Martin Resorts.
• The Right to Limit the Use of Sensitive Personal Information. If Martin Resorts uses or discloses sensitive personal information for reasons other than those permitted by the CCPA, the right to limit the use or disclosure of sensitive personal information by Martin Resorts.
• Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred by the CCPA. 

Martin Resorts will honor the privacy rights afforded to individuals in accordance with applicable law.

Exercising Your CCPA Rights

California residents may submit CCPA requests themselves or using an authorized agent. CCPA requests are subject to our verification measures which vary depending on the type of request made and the sensitivity of the information you request. We may ask you to provide a few pieces of information to confirm your identity in our records. If you authorize an agent to submit a request on your behalf, we may require the agent to provide proof that you gave the agent signed permission to submit the request and may verify the agent’s identity and authority to act on your behalf. 

• Submitting Access, Deletion, and Correction Requests

To make an access, deletion, correction, or limitation request, please use email us at info@kslresorts.com or call us at (800) 401-0686.

• Limiting the Use of Your Sensitive Personal Information

Californian’s have the right to limit a business’s use or disclosure of sensitive personal information. However, Martin Resorts does not use or disclose sensitive personal information for any purpose other than for permissible purposes under the CCPA.

• Opting Out of the Sale/Share of Your Personal Information

To make a request to opt-out of sale and/or sharing of personal information email us at info@kslresorts.com or call us at (800) 401-0686.

Other California Disclosures

California Shine the Light Disclosures: California Civil Code Section 1798.83 permits visitors to our Sites and users of our Services who are California residents to request, once a year, certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please send us an email at info@kslresorts.com include “Shine the Light Request” in the subject line.

Notice of Financial Incentive

We may offer our customers loyalty and other incentive programs that provides certain benefits, such as rewards and exclusive offers. We may also provide other promotional campaigns, such as sweepstakes, contests, or limited-time promotions (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under the CCPA. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. Participation in a Program is governed by the applicable terms and conditions (including the Official Rules for any sweepstakes or contest or the promotional terms for any short-term promotion), which will also describe the financial incentives association with the promotion and how to participate. You are not obligated to participate in any contest, sweepstakes, or short-term promotion and may terminate your participation at any time (as described in the survey terms and conditions). You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program terms and conditions.

Contact Us Regarding Your Privacy Rights

If you would like additional information related to your privacy, please email us at info@kslresorts.com. Please submit your CCPA rights requests using the methods described above.

Updates to Our California Privacy Policy

We may update this California Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the page and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).

Contacting Us

To ask questions or comment about this California Privacy Policy and our privacy practices, contact using one of the following methods:

Email: info@kslresorts.com

Mail: Martin Resorts, c/o CCC Portfolio Management, LLC

18565 Jamboree Road, Suite 500, Irvine, CA 92612